Having secured legal representation due to some kind donations, our lawyers have now submitted their Letter of Representation. The letter covers 11 pages of detailed legal arguments identifying many ways in which the Planning Application falls short of meeting the policies stated in the Local Plan. The first point that the Solicitors establish is that planning should only be approved if the application accords with the policies in the Local Plan. They continue to explain how the following Local Plan policies are either not met, or are at risk of not being met:
- NE03 – Arboriculture / Landscaping,
- NE01 – Wildlife and Habitat Protection / Protected Species,
- MG04 – Health,
- BE12 – Transport / Infrastructure,
- BE08 – Strategic Transport Infrastructure,
- NE08 – Air Quality,
- BE14 – Noise,
- BE05 – Drainage,
- NE09 – Flood Risk.
You can view the letter in full below (we have redacted references to the solicitors we have used):